Clarification over the open letter of Director of "Sv Jur" LLC

23-04-2019

With reference to the open letter of the Director of "Sv Jur" LLC, disseminated on the Internet, we inform that the Ministry of Nature Protection gives no advice to any entrepreneur, thus the environmental impact assessment and expertise of any envisaged activity is supervised in accordance with the defined order of the law on "Environmental Impact Assessment and Expertise".   The reports with required documents and justifications of the organization submitted for examination have not been fully elaborated, not meeting the requirements of Clause 9 of the law, about which the Ministry of Nature Protection has recorded 13 remarks.
Everyone who finds that his rights have been violated by any act of state bodies is free to challenge them within the framework of the RA legislation.
The above mentioned case took a note of  the envisaged activity, and the first task of any venturer is to assess his own risks, which supposes that before receiving  all the permits prescribed  by law, it is necessary to refrain from initiating any other process.
The remarks of the MNP on the draft of "Sv Jur" LLC submitted for examination are attached hereto
1. The draft documents linked to the report are incomplete, and draft documents over the bottling workshop have not been submitted.
2. The environmental assessment related to exploitation and closure phases of the bottling workshop lacks.
3. The environmental impact assessment of the pipe installation (70m) is not presented.
4. There is no information about drainage, the total cost of technical water, the source of supply, inclusive of the quantity and discharge of industrial effluents from the workshop.
5. According to the report, mineral water is abstracted from 6/64 well, and 1/62 well is envisaged for carbon dioxide drilling in the mine. There are no draft solutions for carbon dioxide extraction from 1/62 well and the environmental impact assessment.
6. The plan of actions addressed to reducing environmental impact is incomplete; besides, the measures directed to lessening the possible impacts of pipe installation (70m) and construction of the bottling workshop lack. The deadline for implementation of measures, total cost estimates have not been submitted.
7. The description of the potentially affected area, the environment, natural conditions, resources and their use is inaccurate; the report illustrates mainly the environmental description of Kotayk region.
8. Also, the alternative options are not completed, including the waiver (zero) version, the justification of the selected version in terms of environmental protection, economic and social aspects.
10. The evaluation of full-fledged and total impacts of existing wells and envisaged activities in the mine lack.
11. There is no assessment of possible economic damage to the environment.
13. According to the note submitted by "V & A Tour" LLC to the Ministry of Nature Protection, the sanitation sewage zone of Arzni mineral water mine, on a rental basis, has been belonging to "V & A Tour" LLC since 24.06.2010. There is no agreement with "V & A Tour" LLC on the implementation of activities in the territory specified by "SV JUR" LLC.

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